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Letter Writing Campaign to the Coastal Commission

Written Public Comment:

The California Coastal Commission approved three key permits that allowed the illicit Cal-Am Slant Well Desalination Project in Marina, CA to advance. We anticipate further permitting actions by the CCC in the near future. We wish to communicate the following points:

Good Science has been overlooked and not applied in the issues of:

Dramatic decline of Western Snowy Plover at closest sites to the Cal-Am test slant wells at the Cemex site!

Harm to the Salinas Valley Groundwater Basin from which Cal-Am plans to illegally take water!

If you can't make the Coastal Commission meeting use current letter below to tell the California Coastal Commission they have failed to protect our coastline from the proposed Cal Am slant well project.We need to get our message front and center!

I am opposed to the proposed Cal-Am slant well desalination project in Marina, CA for the following reasons:

COMMUNITY VALUES: Placing an industrial facility of a 10 slant well desalination project on the Cemex property which, last year, the CA Coastal Commission hailed a big victory over the sandmining operations at this very site is inconsistent with regional community values. The CCC with a cease and desist order to stop the sandmining operations, designated this property to be transferred to a public agency (agencies) for conservation purposes in perpetuity. This was with the collective voices of residents all across the Monterey Bay who value our natural beauty and the sensitive habitats of our coastline.

ENVIRONMENTAL INJUSTICE: Community values of equity and fairness to the residents in Marina and Ord communities must be addressed as this section of the Monterey Bay will be subjected to significant damaging environmental impacts. This project is the clearest kind of environmental injustice as it gives precedence to a private, for-profit corporation privatizing water resources at the expense of a small socio-economically challenged community of Marina and forces further rate increases to the Peninsula and Seaside customers who already pay the highest water rates in the country.

SNOWY PLOVER WILL NOT BE PROTECTED: The Final Environmental Impact Report states: “The impacts to the Western Snowy plover and habitat from construction of the nine subsurface slants wells and the test well may have lasting effects on snowy plover behavior and would be significant” and “Maintenance of the subsurface slant wells every five years would result in the permanent loss of approximately 6 acres of potential western snowy plover habitat.” This is unacceptable at the very site that has been designated by the CA Coastal Commission for conservation in perpetuity after the cessation of the sand mining operations in 2020. WSP populations on 3 Marina sites have plummeted since the construction and operation of the one test slant well three years ago! Furthermore, Cal-Am’s desalination project is unnecessary in meeting the Carmel River Cease & Desist Order; other viable recycled water sources are currently available that will provide the Peninsula with water for the next 10 years!

USE BEST SCIENCE AVAILABLE: CalAm falsely asserts that the AEM (Airborne electro-magnetics) subsurface imaging data by Stanford University provides no significant additional information to the evaluation of “no harm”. In choosing a technology with grossly limited data as the preferred methodology to evaluate the risk to an entire basin, while refusing data from an already available and completed state-of-the-art AEM study, the public has been denied assurance that a robust scientific investigation has been used to evaluate this project’s risk to the Salinas Valley Groundwater Basin.

UNACCOUNTED COSTS: The “feasibility” of the project is not only the issue of physical harm to a region’s water supply, but also includes harm to ratepayers who must pay for the exorbitant costs of a for-profit corporation that stands to reap significant financial benefits of owning a new experimental technology, yet having paid nothing for its research and development. Additionally, there has been no mandates to mitigate future OR even the current damage to the environment and the already visible harm to the Western Snowy Plover. This factual data should not be minimized and excused while further damage will be allowed to occur in the future should this project be approved.

VIOLATIONS OF THE MARINA LOCAL COASTAL PLAN: Although Cal-Am acknowledges that their project would be “inconsistent with the City of Marina LCLUP policies governing protection of Primary and Secondary Habitats, a significant and unavoidable impact”, Cal-Am is counting on the CCC to make exceptions for secondary circumstances outlined in the CA Coastal Act. However, the main concerns of environmental protection are from:

The CA Coastal Act: “it is necessary to protect the ecological balance of the coastal zone and prevent its deterioration and destruction” (Section 30000).

The CA Coastal Commission mission: “protecting and enhancing California’s coast and ocean for present and future generations. It does so through careful planning and regulation of environmentally-sustainable development, rigorous use of science, strong public participation, education, and effective intergovernmental coordination”.

The City of Marina’s Local Coastal Plan: “Primary habitat areas shall be protected and preserved against any significant disruption of habitat values and only uses dependent on those resources shall be allowed within those areas.”

Copy and paste into an email or use the downloadable Word file format below

To: California Public Utilities Commission (CPUC) MPWSP-EIR@esassoc.com The Monterey Bay National Marine Sanctuary (MBNMS) montereybay@noaa.govRE: Response to the Final Environmental Impact Report for the MPWSPDate: _____________________

Many valid concerns were voiced by the public regarding the Cal-Am slant well desalination project proposed in Marina, CA in the DEIR/EIR in 2017. The CPUC and the MPMNS have concluded that our concerns will not require any changes of significance to the 2018 FEIR/EIS. I am registering my complaints here.

I agree with all the content of the Citizens for Just Water response that includes these criticisms of the FEIR:

COMMUNITY VALUES: The FEIR fails to address community values of equity and fairness to the residents in Marina and Ord communities that will be subjected to the most damaging environmental impacts and risks of this project. At every opportunity, Cal-Am has sought to deemphasize the location and its impact on Marina water users and has failed in public outreach to the communities most affected by the slant wells. There are currently alternative regional solutions already available and affordable!

ENVIRONMENTAL INJUSTICE: This project is the clearest kind of environmental injustice as it gives precedent to a private, for-profit corporation privatizing water resources at the expense of a small socio-economically challenged community of Marina and forces further rate increases to Peninsula and Seaside customers already paying the highest water rates in the country. This project is not a regional water solution.

BRACKISH WATER IS GROUNDWATER: This project has been changed from its original permit obligation of a “subsurface ocean intake” to an illegal groundwater take from another water jurisdiction. Now the false claim is that brackish water is “useless” and can therefore be taken by Cal-Am, disregarding the fact that brackish water is still groundwater to which Cal-Am has no legal water rights.

SNOWY PLOVER WILL NOT BE PROTECTED: As stated in the FEIR: “The impacts to the plover and habitat from construction of the nine subsurface slants wells and the test well may have lasting effects on snowy plover behavior and would be significant” and “Maintenance of the subsurface slant wells every five years would result in the permanent loss of approximately 6 acres of potential western snowy plover habitat.” This is unacceptable as this very same site has been designated by the CA Coastal Commission for conservation in perpetuity after the cessation of the sand mining operations in 2020.

SEAWATER INTRUSION: The FEIR concludes that this project will “reverse” seawater intrusion yet no scientific proof has been offered for this opinion that goes contrary to all accepted science of seawater intrusion and mitigation strategies. This large experimental project has the potential for devastating impacts in the region, and as such, requires rigorous academic third party research to prove that there will be absolutely “no harm”. No mitigation measure will make Marina whole again.

USE BEST SCIENCE AVAILABLE: The FEIR falsely asserts that the AEM subsurface ground imaging data by Stanford University provides no significant additional information to the evaluation of “no harm”. By choosing a technology with limited data as a preferred methodology in the face of an already available and completed state-of-the-art science study, the CPUC has denied public reassurance that the a robust investigation has been used to evaluate this project.

UNACCOUNTED COSTS: The “feasibility” of the project is not only the issue of physical harm to a region’s water supply, but also includes harm to ratepayers who must pay for the exorbitant costs of a for-profit corporation that will reap financial benefits of advancing a new technology. Additionally, costs for mitigation must be figured in which means identifying upfront money for proactive protection against harmNOT merely paying to rectify harm done in the future!

Date: ________________Dear Mr. Michel and Mr. Forsythe,I am writing as a concerned resident of the City of Marina regarding the release of the Environmental Impact Report for the Monterey Peninsula Water Supply Project; I hope you take my comments into consideration.The residents of Marina have expressed a number of serious concerns with this project, particularly the use of the slant wells, and how it will disproportionately impact our community and way of life. And yet the Final EIR fails to provide adequate discussion of these harmful impacts or appropriate mitigations. Marina is already home to the regional landfill as well as the regional sewage treatment plant. This proposed desalination project would saddle our community with another operation that only benefits the interests surrounding us, while posing extreme threat to our groundwater and coastal ecosystem. The following outlines my most serious concerns, among the many others.

The Salinas Valley Groundwater Basin (SVGB), from which the project seeks to draw its water, is the same source that Marina residents rely on as our sole source of drinking water. Installing up to 10 slant wells into the basin will further deplete this source, cause saltwater intrusion, and leave Marina residents without a reliable drinking source.

The Marina community worked for years to end the CEMEX sand mining operation that was destroying this area’s coastal habitat. Allowing Cal Am to now drill water wells in this exact same location furthers industrial use in an area that should be protected, and undermines local sustainability efforts.

Cal Am has no water rights to draw from this source. Allowing this project to move forward based on speculation that water rights will ‘likely’ be established is irresponsible. This project is also shockingly inconsistent with the intent of California’s Sustainable Groundwater Management Act, which aims to finally put in place protections for critically overdrafted groundwater basins like this one.

Other options are available to meet the true water supply needs of the region. Expansion of the Pure Water Monterey recycled water project as well as other collaborative solutions could adequately address regional water demand while ensuring that Marina isn’t left behind with long-term harm.

The EIR disregards or trivializes this project’s clear environmental injustice, lack of water rights, violation of the Sustainable Groundwater Management Act, and impacts to Marina’s sole source of drinking water. I encourage the Public Utilities Commission to provide a more fair analysis of the project’s harm to the city of Marina and potential mitigations or alternatives that could avoid this. As a resident of the area potentially impacted by Cal-Am’s MPWSP, I support the efforts of the City of Marina, Marina Coast Water District, Citizens for Just Water, Public Water Now, and Water Plus and thereby incorporate, by reference, every comment, criticism, and identified deficiencies related to the FEIR identified by these entities.Print Name:________________________________ Signed: ____________________________________ Email:____________________________________ Address: ____________________________________